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Cohan v. Commissioner
United States Court of Appeals for the Second Circuit
39 F.2d 540 (1930)
George M. Cohan was a theatrical composer, director, and producer. Due to the nature of his work, Cohan often spent money entertaining actors, employees, and critics, and he frequently traveled for work. Cohan deducted his business expenses on his tax returns, but because he did not keep track of how much he spent, he had to estimate the total amount. During an appeal to the Tax Board of Appeals (the Board), Cohan gave estimates of tens of thousands of dollars spent for business-related purposes for each relevant fiscal period. The Board held that even though Cohan had deductible business expenses, he could not claim a deduction because he could not prove how much he had spent. Cohan appealed.
Rule of Law
Holding and Reasoning (L. Hand, J.)
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